I-140, Intent To Deny, NEED HELP !!!

A

agbaik

Registered Users (C)
I have posted it yesterday in “I-140 issues” but I think it actually belongs here.
Apologies for double-posting.


First of all I want to thank all members of this forum for keeping helping people like me to go through the immigration process madness!

I am posting here for the first time although it was the first source of information for me while preparing my petition.
I have received NOTICE OF INTENT TO DENY and need your advice on how to proceed.

My summary:

• Filed self prepared I-140 to TSC through e-file 04/15/07
• PhD in physics from intermediate US university (2005)
• 11 published papers in intermediate and highly ranked journals
• First author paper cited 60 times, others – 110 times, 170 total
• Employed in small R&D company for two years on H1B status, working in physics applications for medical research in obesity and diabetes

The INTENT TO DENY states:

1. not enough proof to wave labor certification

I have used the following: Specialist in multiple disciplines – no category exist in labor certification process to evaluate all my skills.

2. Relative to my employment bringing benefits to National Interest. It states that I have proven that I have accomplished in the field and the field is importunt to national interest but: “There must be proven results and an acceptable level of implementation of such results into society and practices in the field. The evidence submitted does not convince this Service that such level of achievement has been achieved”

I have used published articles, conference presentations, awards and quotes from reference letters.

So far this is what I plan to send in response:
1. Labor certification
• Company is going to apply for grants from USDA, FDA, and DOD (application of our technique in security systems) for various systems development – some of them require residency status of key researchers. Lengthy labor certification will restrict me from being in this grants which will delay systems development and effect national interest.

2. Proven results and implementation
• Since the petition filing, one grant with me as one of the key researchers submitted to FDA was approved. I don’t have yet official approval notice but I’ll try to get something.
• My citations grew a little from 170 to 200 – I will try to present it in a nice form.
• I will get reference letters and statements about company sales increase and instruments overall improvements as a result of work.


If you could give me your opinion on my situation – you’ll help a lot. If you could share additional ideas and answer my questions – you’ll save me!

Questions:
1. How different a reply to INTENT TO DENY from reply to RFE should be?
2. Any ideas how long cover letter should be?
3. What else I could use to justify Labor Certification wave? Couldn’t really find one to look strong.
4. I have read that the documents could get lost in the mail room but people receive INTENT TO DENY or RFE. The advice was to call Service Center and ask. If this is actually happened, do you think they will tell? After all they’ve sent a response meaning that they have the documents.
5. Would the reference letters help me considering the type of proof they ask? If yes – what should be covered in them?

I am ready to fight!!! I just want to make sure that my response will be straight to the point.

I apologies if I am asking too much, but I really need your advice!!!
 
Sorry to hear, Even NIW is getting difficult these days! There were days when everyone got NIW and EB1-EA with few publications and citations. If your package had lost in the mail room, you would have got RFE. it is also strange that you got NOID without RFE.
 
You have a strong file for what is related to your value in your field of work. The problem is that you have to demonstrate why skipping the LC process is that important for your work.

Looking at your situation with devil's eyes:
- You have 4 years left of H1B, plus all the yearly extension you get while waiting for the process to be done.
- You are going to do what you present in your file as projects whether you go through NIW or through a normal LC process: a proof of that is that you are part of a new grant since you sent your I-140...
- "Multiple skills" is not necessarily a good reason to by-pass LC.

In other terms, you have to be very careful not to use arguments that could actually come back against your case.

Chris
 
To ChrisV:



It always god to have "devils advocate" - brings you down to reality.
Thank you for your points. You're absolutely right - 4 year on H1B kills time constrain reason for LC. The new grant approval I will use to prove the implementation of my work to address the second question in NOID. "Multiple skills" is a weak bullet, you're right. I was actually hoping that the field importance to National Interest, and benefits I bring will compensate for weak LC wave justification. This was the plot I used to build the cover letter, after all is Obesity and Diabetes! I was wrong.

What I need now is a strong reason to justify LC wave for the first point in NOID. The second one, I think I can get away by showing some proof that the stuff I did is actually working and bringing benefits in the field.

Unfortunately I lack the knowledge about the LC process.
Does anybody know how it works?
Maybe you have a link to the info about LC, may be the one written for regular peoples, not layers?

Appreciate any help you can give!
 
agbaik said:
To ChrisV:



It always god to have "devils advocate" - brings you down to reality.
Thank you for your points. You're absolutely right - 4 year on H1B kills time constrain reason for LC. The new grant approval I will use to prove the implementation of my work to address the second question in NOID. "Multiple skills" is a weak bullet, you're right. I was actually hoping that the field importance to National Interest, and benefits I bring will compensate for weak LC wave justification. This was the plot I used to build the cover letter, after all is Obesity and Diabetes! I was wrong.

What I need now is a strong reason to justify LC wave for the first point in NOID. The second one, I think I can get away by showing some proof that the stuff I did is actually working and bringing benefits in the field.

Unfortunately I lack the knowledge about the LC process.
Does anybody know how it works?
Maybe you have a link to the info about LC, may be the one written for regular peoples, not layers?

Appreciate any help you can give!
Click to expand...

In short, the purpose of LC is to serve US national interest by employing US worker for the job you (alien) are seeking- if the US person is minimally qualified to perform the job

While admitting that I am also clueless about how to argue for waiving LC, hope that you have read this document. This is a must read for NIW- also for EB1. Pages 57-61 covers NIW.

Going through it again, USCIS says that there are two competing `national interests': (i) the inherent National Interest in going through LC (making job available to a US person) (ii) The national interest you claim.

So there is this `national interest balance' where you put the case of harming the US interest by denying chances to a US worker vs benefits to US by granting you waiver.

Certainly, (ii) has to outweigh (i). The way to prove (I think) is:

Show that:
  1. Arguments showing losses to US interest by denying you waiver [x points]
  2. You may also want to say that you see an inherent national interest in protecting US worker [y points]
  3. Arguments showing that by denying you- the expert in the field- an opportunity to serve US interest (and offering this to a minimally qualified US person- instead), US will lose in ....,. (Your arguments should show that sum of the above (x+y) is negative).

In addition to the above, you should show that you can do the job much better than a minimally qualified person (your letters should say that ``his/her level of expertise stands way beyond a person who is having his/her level of education''- or ``it is fair to say that s/he is a standout amongst her/his peers'').

I am still not done with my NIW preparation. So, I am not an expert- just scribbling down some suggestions so that experts (like Chris) can comment.

It seems that establishing NIW is getting tougher than EB1.
 
Your background is good enough to make a strong and fairly easy NIW case. I suspect your self-prepared petition letter is flawed since the NOID you received questioned why you have to waive laber certification. I think now you should find a lawyer to answer this NOID letter since it is more serious than a plain RFE. In my opinion, paying the lawyer a couple of grands is much better than losing your NIW application. just my 2 cents.
 
Hi agbaik
If you prepare good cover letter for your reply, you can get NIW.
Address the following points in detail:
1) My work is in an area of substantial intrinsic merit;
2) The benefit of my work is national in scope;
3) My ability to perform the duties in my research projects on the …………………………. is significantly above the peers;
4) The national interest would be adversely affected if a labor certification were required for myself (follow other members suggestions for this point)
5) My past accomplishments justify projections of future benefit to the national interest.

All the best
 
So EB10182006
I am in the process of preparing the cover letter as well and this is exaclty how I am organizing it. I was able to get one filed by a lawyer and that is how they address it as well.
However, they do not discuss the issue of waiving a labor certification clearly.
Can you give us idea on how to exaclty argue for this, you have also mentioned that there are posts commenting on this, can you give us a link, I tried searching but wasn't successful.

It is amazing how much help I am getting from this forum! Absolutetly more help than from people whom I personally know well.
SO thank you.
hnks
 
EB10182006 said:
Hi agbaik
If you prepare good cover letter for your reply, you can get NIW.
Address the following points in detail:
1) My work is in an area of substantial intrinsic merit;
2) The benefit of my work is national in scope;
3) My ability to perform the duties in my research projects on the …………………………. is significantly above the peers;
4) The national interest would be adversely affected if a labor certification were required for myself (follow other members suggestions for this point)
5) My past accomplishments justify projections of future benefit to the national interest.

All the best
Click to expand...
Hi EB10182006

Your inputs are appreciated. The points you listed, I think every one addresses (hope !) in their petition. The crucial question is how do you make a valid point for (4) above ?. You may have to show that benefits of your employment outweighs the damage you did to national interest by kicking out a US person who was qualified to do the job. The key not just that you are better than that person (that point has to be there), but your arguments also should be such that your employment is so much important to US interest such that it will repair the damage you did by denying the opportunity to a US worker- and then add to national interest. At least this is what I understand when I read USCIS documents (see my post above).
 
Hi Helpinghand

I agree your point is the key for NIW.

The Adjudicator’s Field Manual (AFM) says the following, this may be useful:

National Interest Waiver of Job Offer:

Since 1990 the Act has provided that an alien of exceptional ability may obtain a "waiver of job offer" if such waiver is deemed by the agency to be in the "national interest." A subsequent technical amendment extended the job offer waiver to certain professionals. Since this waiver provision is included in section 203(b)(2) of the Act, it applies only to professionals holding advanced degrees and exceptional ability aliens. In fact, the regulations, at 8 CFR 204.5(k)(4)(ii) provide that a waiver of a job offer also includes a waiver of the labor certification requirement. The petitioner may file Form ETA-750, Part B, or Form ETA-9089, in duplicate, in support of the petition. Either form is acceptable. Legacy INS initially proposed limiting the national interest waiver to occupations where self-employment is common or traditional or to an occupation in the DOL's pilot program. However, commenters to the proposed rule questioned whether the waiver of job offer really meant waiver of labor certification. Therefore, the final regulation deleted the requirement of self-employment or listing in the pilot program and states only that it must be shown that the waiver would be in the national interest.
Section 203(b)(2) of the Act requires that all aliens seeking to qualify as having exceptional ability show that their presence in the United States would substantially benefit prospectively the national economy, cultural or educational interests or welfare of the United States and adds the additional test of "national interest" to those who wish the job offer waiver. Neither Congress nor legacy INS defined the term "national interest" in either the Act or the regulations in order to leave the application of this test as flexible as possible. However, an alien seeking to meet the national interest standard must show significantly more than "prospective national benefit" required of all aliens seeking to qualify as having exceptional ability. The burden rests with the petitioner to establish that exemption from, or waiver of, the job offer requirement will be in the national interest. Each case is to be judged on its own merit.

In 1998, the Administrative Appeals Office (AAO) issued a precedent decision, Matter of In Re: New York State Department of Transportation, 22 I&N Dec. 215 (Comm. 1998) (“NYSDOT”), which created a three-prong test for petitioners seeking a national interest waiver. You should remember that the purpose of these prongs is to set minimum requirements for activities that are in the national - not local - interest. These minimum requirements follow:
• Under the first prong of the NYSDOT test, the alien must seek employment in an area that has substantial intrinsic merit. In NYSDOT, the alien was a structural engineer working on highway bridges. This activity was found to have substantial intrinsic merit. It is obvious that the protection of motorists and the maintenance of a highway system are activities of substantial intrinsic merit. By contrast, a person who is a juggler and asserts that he or she wishes to perform at children's birthday parties, might not meet this requirement. While the alien's proposed activity is not deleterious, it would be difficult to claim that such an activity has "substantial" intrinsic merit for purposes of establishing the "national" interest.

• The second prong of the NYSDOT test requires that the waiver applicant demonstrate that the proposed benefit to be provided will be national in scope. There are many activities which have positive effects, such as job creation for a local community, but may in fact have a limited, or even
negative, national impact. For example, an alien may be sought as a loan officer for a regional bank. The alien’s clients may come from various parts of the country, but the primary purpose of the alien’s employment is to benefit the regional bank, not to benefit the nation as a whole. The principal aim of the alien’s activities is to benefit the bank, not the nation. As another example, an alien may be sought to manage a waste disposal facility for a municipal government. That facility, however, may be contributing to pollution of a nearby river. While the alien’s activities might result in the preservation of local jobs, his or her activities might in fact have a detrimental effect on other communities lying along the path of the stream or river, even those located in other states. Therefore, any interest in hiring this person would be local at best, and could not be deemed to be national in scope or in the “national” interest.

On a related note, the basis for the waiver may not be the existence of a local labor shortage. The mere fact that the alien might fill a locally needed position - irrespective of the positive effect of such activity - does not qualify the activity as being in the national interest. While there exists a generalized national interest in providing jobs to all work authorized persons, the national interest waiver is a waiver of the labor certification requirement - it is not a substitute for this requirement. Congress specifically created the labor certification process in order to test the domestic local labor market. A shortage of qualified workers in a given field does not constitute grounds for a national interest waiver. Given that the labor certification process was designed to address the issue of worker shortages, a shortage of qualified workers is an argument for obtaining rather than waiving a labor certification. (As noted below, however, following issuance of the NYSDOT precedent, Congress created an exception for certain physicians who are working in medically underserved or needed areas).
• Finally, under the third prong of the NYSDOT test, it must be demonstrated that the national interest would be adversely affected if the employer is required to proceed with the labor certification process. In order to satisfy the third component of the test, therefore, it must be shown "that it would be contrary to the national interest to potentially deprive the prospective employer of the services of the alien by making the position sought available to U.S. workers." In addition, NYSDOT further requires, as a condition of meeting the third prong, "that the alien will serve the national interest to a substantially greater degree than would an available U.S. worker having the same minimum qualifications." This test recognizes that there can be two competing "national interests" - the national interest, as set forth by Congress in section 212(a)(5) of the INA, of requiring a test of the labor market versus the "national interest" in fulfilling a permanent need for the alien's services.
Given the variety of occupations potentially covered by the waiver, a single set of standards applicable to all cases is impractical. Therefore each determination must be made on a case-by-case basis and will depend on an assessment of the specific facts presented.

To meet the third prong, the petitioner might be able to demonstrate that the need for the alien’s services is so great that the national interest would not be properly served were the petitioner required to postpone employment of the alien until the labor certification process is completed. An example would be the need for an alien epidemiologist to work on prevention of an epidemic following a natural disaster. Obviously, time would be of the utmost essence in such a case.
It should be remembered that while the NYSDOT decision sets forth these three minimum criteria which must be met in order to establish eligibility for a national interest waiver, the presence of these factors, alone do not necessarily mean that you must grant the waiver. For example, an alien with a criminal background might meet the above criteria, yet still might not merit a discretionary grant of the waiver. You should consider all the facts presented in making your determination.
In addition to the above, you should also bear in mind the following general considerations with respect to adjudicating requests for national interest waivers:
• An alien seeking immigrant classification as an alien of exceptional ability or as a member of the professions holding an advanced degree cannot meet the threshold for a national interest waiver of the job offer requirement simply by establishing a certain level of training or education which could be articulated on an application for a labor certification.

• General arguments regarding the importance of a given field of endeavor, or the urgency of an issue facing the U.S., cannot by themselves establish that an individual alien benefits the national interest by virtue of engaging in the field or seeking an as yet undiscovered solution to the problematic issue.

In all cases, while the national interest waiver hinges on prospective national benefit, it clearly must be established that the alien’s past record justifies projections of future benefit to the national interest. The petitioner’s subjective assurance that the alien will, in the future, serve the national interest cannot suffice to establish prospective national benefit if the alien has few or no demonstrable achievements.

All the best
EB10182006
 
EB10182006 said:
Hi Helpinghand

I agree your point is the key for NIW.

The Adjudicator’s Field Manual (AFM) says the following, this may be useful:

National Interest Waiver of Job Offer:

Since 1990 the Act has provided that an alien of exceptional ability may obtain a "waiver of job offer" if such waiver is deemed by the agency to be in the "national interest." A subsequent technical amendment extended the job offer waiver to certain professionals. Since this waiver provision is included in section 203(b)(2) of the Act, it applies only to professionals holding advanced degrees and exceptional ability aliens. In fact, the regulations, at 8 CFR 204.5(k)(4)(ii) provide that a waiver of a job offer also includes a waiver of the labor certification requirement. The petitioner may file Form ETA-750, Part B, or Form ETA-9089, in duplicate, in support of the petition. Either form is acceptable. Legacy INS initially proposed limiting the national interest waiver to occupations where self-employment is common or traditional or to an occupation in the DOL's pilot program. However, commenters to the proposed rule questioned whether the waiver of job offer really meant waiver of labor certification. Therefore, the final regulation deleted the requirement of self-employment or listing in the pilot program and states only that it must be shown that the waiver would be in the national interest.
Section 203(b)(2) of the Act requires that all aliens seeking to qualify as having exceptional ability show that their presence in the United States would substantially benefit prospectively the national economy, cultural or educational interests or welfare of the United States and adds the additional test of "national interest" to those who wish the job offer waiver. Neither Congress nor legacy INS defined the term "national interest" in either the Act or the regulations in order to leave the application of this test as flexible as possible. However, an alien seeking to meet the national interest standard must show significantly more than "prospective national benefit" required of all aliens seeking to qualify as having exceptional ability. The burden rests with the petitioner to establish that exemption from, or waiver of, the job offer requirement will be in the national interest. Each case is to be judged on its own merit.

In 1998, the Administrative Appeals Office (AAO) issued a precedent decision, Matter of In Re: New York State Department of Transportation, 22 I&N Dec. 215 (Comm. 1998) (“NYSDOT”), which created a three-prong test for petitioners seeking a national interest waiver. You should remember that the purpose of these prongs is to set minimum requirements for activities that are in the national - not local - interest. These minimum requirements follow:
• Under the first prong of the NYSDOT test, the alien must seek employment in an area that has substantial intrinsic merit. In NYSDOT, the alien was a structural engineer working on highway bridges. This activity was found to have substantial intrinsic merit. It is obvious that the protection of motorists and the maintenance of a highway system are activities of substantial intrinsic merit. By contrast, a person who is a juggler and asserts that he or she wishes to perform at children's birthday parties, might not meet this requirement. While the alien's proposed activity is not deleterious, it would be difficult to claim that such an activity has "substantial" intrinsic merit for purposes of establishing the "national" interest.

• The second prong of the NYSDOT test requires that the waiver applicant demonstrate that the proposed benefit to be provided will be national in scope. There are many activities which have positive effects, such as job creation for a local community, but may in fact have a limited, or even
negative, national impact. For example, an alien may be sought as a loan officer for a regional bank. The alien’s clients may come from various parts of the country, but the primary purpose of the alien’s employment is to benefit the regional bank, not to benefit the nation as a whole. The principal aim of the alien’s activities is to benefit the bank, not the nation. As another example, an alien may be sought to manage a waste disposal facility for a municipal government. That facility, however, may be contributing to pollution of a nearby river. While the alien’s activities might result in the preservation of local jobs, his or her activities might in fact have a detrimental effect on other communities lying along the path of the stream or river, even those located in other states. Therefore, any interest in hiring this person would be local at best, and could not be deemed to be national in scope or in the “national” interest.

On a related note, the basis for the waiver may not be the existence of a local labor shortage. The mere fact that the alien might fill a locally needed position - irrespective of the positive effect of such activity - does not qualify the activity as being in the national interest. While there exists a generalized national interest in providing jobs to all work authorized persons, the national interest waiver is a waiver of the labor certification requirement - it is not a substitute for this requirement. Congress specifically created the labor certification process in order to test the domestic local labor market. A shortage of qualified workers in a given field does not constitute grounds for a national interest waiver. Given that the labor certification process was designed to address the issue of worker shortages, a shortage of qualified workers is an argument for obtaining rather than waiving a labor certification. (As noted below, however, following issuance of the NYSDOT precedent, Congress created an exception for certain physicians who are working in medically underserved or needed areas).
• Finally, under the third prong of the NYSDOT test, it must be demonstrated that the national interest would be adversely affected if the employer is required to proceed with the labor certification process. In order to satisfy the third component of the test, therefore, it must be shown "that it would be contrary to the national interest to potentially deprive the prospective employer of the services of the alien by making the position sought available to U.S. workers." In addition, NYSDOT further requires, as a condition of meeting the third prong, "that the alien will serve the national interest to a substantially greater degree than would an available U.S. worker having the same minimum qualifications." This test recognizes that there can be two competing "national interests" - the national interest, as set forth by Congress in section 212(a)(5) of the INA, of requiring a test of the labor market versus the "national interest" in fulfilling a permanent need for the alien's services.
Given the variety of occupations potentially covered by the waiver, a single set of standards applicable to all cases is impractical. Therefore each determination must be made on a case-by-case basis and will depend on an assessment of the specific facts presented.

To meet the third prong, the petitioner might be able to demonstrate that the need for the alien’s services is so great that the national interest would not be properly served were the petitioner required to postpone employment of the alien until the labor certification process is completed. An example would be the need for an alien epidemiologist to work on prevention of an epidemic following a natural disaster. Obviously, time would be of the utmost essence in such a case.
It should be remembered that while the NYSDOT decision sets forth these three minimum criteria which must be met in order to establish eligibility for a national interest waiver, the presence of these factors, alone do not necessarily mean that you must grant the waiver. For example, an alien with a criminal background might meet the above criteria, yet still might not merit a discretionary grant of the waiver. You should consider all the facts presented in making your determination.
In addition to the above, you should also bear in mind the following general considerations with respect to adjudicating requests for national interest waivers:
• An alien seeking immigrant classification as an alien of exceptional ability or as a member of the professions holding an advanced degree cannot meet the threshold for a national interest waiver of the job offer requirement simply by establishing a certain level of training or education which could be articulated on an application for a labor certification.

• General arguments regarding the importance of a given field of endeavor, or the urgency of an issue facing the U.S., cannot by themselves establish that an individual alien benefits the national interest by virtue of engaging in the field or seeking an as yet undiscovered solution to the problematic issue.

In all cases, while the national interest waiver hinges on prospective national benefit, it clearly must be established that the alien’s past record justifies projections of future benefit to the national interest. The petitioner’s subjective assurance that the alien will, in the future, serve the national interest cannot suffice to establish prospective national benefit if the alien has few or no demonstrable achievements.

All the best
EB10182006
Click to expand...

This is the same document I have provided the link (in my post #5 above). Now what we need is based on this document, how can we make a case of National interest is adversely affected if gone through LC.
 
My suggestion for the cover letter preparation is as follow:
In addition to my post#7
A shortage of qualified workers in a given field, regardless of the nature of the occupation, does not constitute grounds for a national interest waiver. Given that the labor certification process was designed to address the issue of worker shortage. First, it must be shown that the alien seeks employment in an area of substantial intrinsic merit. Next, it must be shown that the proposed benefit will be national in scope. Merely serving a regional or local interest is not sufficient. The emphasis of this factor is on the existence of a national goal that the alien will promote. Third, the petitioner seeking the waiver must persuasively demonstrate that the national interest would be adversely affected if a labor certification were required for the alien. An alien seeking an exemption from this process must therefore present a national benefit so great as to outweigh the national interest inherent in the labor certification process. The first step in meeting this test is establishing that the alien possesses unique knowledge, abilities, or experience that set him or her apart from other professionals in the field. The second step is establishing that the applicant will use these unique attributes in an activity that will significantly benefit her/his field of endeavor………………… Beneficiary's contributions to the development and dissemination of innovative research in the field…………………….. invaluable to the …………………… goals of the United States for the next century.
Beneficiary's novel research and overwhelming support from leading members of U.S. governmental agencies, such as the………………………….. The individual is part-way through cutting-edge research in a very specialized field and no one else could finish it………..
Therefore, retaining my rare and unique expertise for the benefit of the national welfare far outweighs the interest in protecting the U.S. labor market, such that a labor certification should not be required in the instant case.

EB10182006
 
EB10182006 said:
My suggestion for the cover letter preparation is as follow:
In addition to my post#7
A shortage of qualified workers in a given field, regardless of the nature of the occupation, does not constitute grounds for a national interest waiver. Given that the labor certification process was designed to address the issue of worker shortage. First, it must be shown that the alien seeks employment in an area of substantial intrinsic merit. Next, it must be shown that the proposed benefit will be national in scope. Merely serving a regional or local interest is not sufficient. The emphasis of this factor is on the existence of a national goal that the alien will promote. Third, the petitioner seeking the waiver must persuasively demonstrate that the national interest would be adversely affected if a labor certification were required for the alien. An alien seeking an exemption from this process must therefore present a national benefit so great as to outweigh the national interest inherent in the labor certification process. The first step in meeting this test is establishing that the alien possesses unique knowledge, abilities, or experience that set him or her apart from other professionals in the field. The second step is establishing that the applicant will use these unique attributes in an activity that will significantly benefit her/his field of endeavor………………… Beneficiary's contributions to the development and dissemination of innovative research in the field…………………….. invaluable to the …………………… goals of the United States for the next century.
Beneficiary's novel research and overwhelming support from leading members of U.S. governmental agencies, such as the………………………….. The individual is part-way through cutting-edge research in a very specialized field and no one else could finish it………..
Therefore, retaining my rare and unique expertise for the benefit of the national welfare far outweighs the interest in protecting the U.S. labor market, such that a labor certification should not be required in the instant case.

EB10182006
Click to expand...

Good points. Thanks !
 
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